Anti-Bribery and Anti-Corruption
Abstract
Endaoment is committed to maintaining the highest standards of integrity and ethical behavior. Our Anti-Bribery and Anti-Corruption (ABAC) Risk Management policy addresses risks associated with unethical or illegal activities, including bribery, corruption, embezzlement, and fraud, within our operations and external engagements. Effective management of these risks is crucial to preserving donor trust and ensuring the long-term success of our mission.
Policy Statement
Endaoment unequivocally prohibits all forms of bribery and corruption across its operations. This policy demonstrates our dedication to preventing, identifying, and addressing bribery and corruption, ensuring transparency and fairness in all business dealings. Compliance with relevant laws and regulations is mandatory for all employees, contractors, board members, and third parties associated with Endaoment.
Risk Management Strategy
Risk Assessment
- Due Diligence Procedures
- Conduct comprehensive due diligence on all potential and existing partners, vendors, and stakeholders to assess their risk levels concerning bribery and corruption.
- Political Exposure Analysis
- Evaluate interactions with government officials or entities to identify and mitigate risks related to political exposure.
Risk Mitigation
- Ethical Guidelines
- Implement and enforce comprehensive ethical guidelines and a Code of Conduct that explicitly prohibit bribery and corruption in all forms.
- Financial Controls
- Establish robust financial controls, including transparent accounting procedures and regular audits, to prevent and detect corrupt practices.
Monitoring and Reporting
- Compliance Monitoring
- Continuously oversee business practices and transactions to ensure adherence to ABAC policies.
- Incident Reporting Mechanism
- Provide a secure and anonymous system for reporting suspected bribery or corruption incidents.
Operational Controls
No Donor Benefit (NDB) Policy
- Donor Communication
- Present the NDB policy to donors (or provide a link) for each donation and require donor attestation.
- Internal Assurance
- Conduct internal reviews to ensure consistent presentation and enforcement of the NDB policy across all donation channels.
3Rs Review Process
- Monthly Financials
- Validate monthly financials through segregation of duties involving a third party, a staff member, and a board member.
- Internal Assurance
- Perform regular internal reviews to ensure the integrity and effectiveness of the 3Rs Review Process.
Hiring Processes
- Government Official Disclosure
- For each new hire, inquire if the candidate or their immediate family members are government officials of any country. If affirmative, require details of the role and governmental organization.
- Escalation
- Escalate affirmative responses to Board review and approval before extending an offer.
- Internal Assurance
- Conduct internal checks to verify that all disclosures are appropriately addressed and escalated.
On-chain Operational Controls
- Blockchain Transparency
- Utilize blockchain transaction transparency to monitor and verify all on-chain activities for signs of corrupt practices.
- Smart Contract Audits
- Ensure all smart contracts undergo rigorous auditing processes to prevent corruption or manipulation.
Off-chain Operational Controls
- Vendor Management
- Implement stringent controls and regular reviews of vendor relationships to ensure compliance with Endaoment’s ABAC standards.
Control Testing
Endaoment conducts comprehensive internal testing to evaluate the effectiveness of our anti-bribery and anti-corruption controls across both on-chain and off-chain operations. These tests ensure ongoing compliance and the continuous improvement of our risk management strategies.